Woodhouse AC Limited v Nigerian Produce Limited [1972]

Contract between parties stated prices in Nigerian
pounds, which were equal in value to British pounds.
W, buyers, in anticipation of devaluation, asked if
payments might be made in sterling.
Sellers agreed.
Following devaluation, sellers demanded payment in
sterling to full contract value in Nigerian pounds.
Buyers contended they only need pay on basis of one
British pound for one Nigerian pound.
Held in House of Lords:
To found a promissory estoppel, a representation must
be clear and unequivocal.
If representation is not so made, it is representee’s problem
if he misconstrues it and relies upon it.
Representation here had not been sufficiently precise to found variation of the
contract, or an estoppel.